1. WHO IS VASCO CONNECT
1. VASCO CONNECT is a lead generation and direct marketing company, specialising in telecoms and value-added service products
2. VASCO CONNECT is a wholly owned subsidiary of COACTIVATE (PTY) LTD
4. Our customers are typically consumers, insurance providers, financial service providers, motor industry providers, asset providers, general maintenance providers, cellular service providers and contact centres and other related service providers.
2. INTRODUCTION AND APPLICATION
3. It also gives our details in case the consumer wants to contact us and query any issues that they may have.
5. In this document any reference to “we” or “us” or “our” includes any one or more of our Affiliates.
6. “Affiliates” means and each business unit, branch and/or representative office of any business of VASCO CONNECT; any subsidiaries of VASCO CONNECT, or companies connected to VASCO CONNECT; and any of VASCO CONNECT’s associates, cessionaries, delegates or successors in title or appointed third parties such as its authorised agents, advisors, partners, and contractors.
3. PROCESSING OF PERSONAL INFORMATION
1. Where we refer to “process”, it means how we collect, use, store, make available, destroy, update, disclose, or otherwise deal with Personal Information.
2. As a rule, we will only process Personal Information if we are required to deliver or offer a marketing service, provide a lead, or carry out a transaction.
5. Sometimes you may provide us with consent to process your Personal Information. Read it carefully because it may limit your rights.
4. WHAT IS PERSONAL INFORMATION
1. Personal Information refers to any information that identifies a consumer or specifically relates to a consumer.
2. Personal Information includes, but is not limited to, the following information:
i. marital status (like married, single, divorced).
ii. national origin.
iv. language; birth; education.
v. debit order and banking details
vi. identifying number (like an account number, identity number or passport number).
vii. e-mail address; physical address (like residential address, work address or your physical location).
viii. telephone number. ix. online identifiers; social media profiles. x. biometric information (like fingerprints, your signature or voice);
xii. physical health; mental health; well-being; disability; religion; belief; conscience; culture.
xiii. medical history (like your HIV / AIDS status); criminal history; employment history.
xiv. personal views, preferences, and opinions.
xv. confidential correspondence; and / or
xvi. another’s views or opinions about you and your name also constitute Personal Information.
3. Personal Information includes Special Personal Information, as explained below.
5. WHEN WILL WE PROCESS YOUR PERSONAL INFORMATION
We will only process Personal Information for lawful purposes relating to our business if the following applies:
1. if, where required, you have consented thereto.
2. if you have not requested that we refrain from processing your Personal Information
3. if a person legally authorised by you, the law, or a court, has consented thereto.
4. if it is necessary to conclude or perform under a contract, we have with you.
5. if the law requires or permits it; and/or 6. if it is required to protect or pursue your, our or a third party’s legitimate interest; and/or
6. WHEN AND WHERE WE OBTAIN PERSONAL INFORMATION ABOUT YOU
1. We collect Personal Information about consumers from various sources, including the following:
i. We collect Personal Information from consumers directly.
ii. We collect information about consumers based on their use of our, services or service channels (like our websites, applications, pre-paid contracts, promotions, and competitions).
iii. We collect information about consumers based on how they engage or interact with us such as on social media, emails, letters, telephone calls, surveys, competitions.
iv. If the law requires us to do so, we will ask for consumer’s consent before collecting Personal Information about you from third parties.
v. people the consumer has authorised to share Personal Information.
vi. our joint venture partners; and / or
vii. other marketing list providers.
7. WHAT DO WE DO WITH PERSONAL INFORMATION
1. We use Personal Information for the following reasons, in line with our business and the purpose for which it is collected:
i. sending marketing communications (SMS, E-mail, AVM, Telephonic Calls, WhatsApp) with the latest specials, deals and promotions in various industries, such as telecoms services, insurance, etc.
ii. to market products, goods, and services to you.
iii. to respond to your enquiries and complaints.
iv. providing information about goods and/or services the consumer may have requested and notifying consumers about important changes or developments to these goods and/or services.
v. to follow up as part of our customer care procedures, updating our records about consumers.
vi. internal record keeping; administering offers.
vii. to improve our products and services.
viii. to comply with legislative, regulatory, risk and compliance requirements (including directives, sanctions, and rules), voluntary and involuntary codes of conduct and industry agreements or to fulfil reporting requirements and information requests.
ix. evaluating the effectiveness of our marketing and for research, training, and statistical analysis with the aim of improving our services.
x. for any other related purposes.
2. We may do these things either for VASCO CONNECT, any entity in the COACTIVATE Group or on behalf of our customers or business partners.
3. At the time you provide us with any information in response to a request from us, our request will provide you with specific information as to how we will use such information.
4. Other than for the direct marketing purposes referred to below, we may contact you by e-mail, telephone, SMS, fax, or mail in relation to the purposes set out in this section and by providing such information you are deemed to have agreed to us contacting you by these methods of communication. We will continue to contact you by way of such methods until you advise us you no longer wish to be contacted by certain methods.
5. We will not pass your details to anyone else (other than on the basis set out below and in accordance with appropriate disclosure requirements we may be subject to).
8. USE OF PERSONAL INFORMATION FOR MARKETING
1. We may provide consumers from time to time with information about new products, promotions, special offers and other information.
2. We will use Personal Information to market financial, insurance, investments, credit, cellular phone and other products and services to you.
3. We may also market other products, goods, or services to you.
4. We will do this in person, by post, telephone, or electronic channels such as SMS, email, and fax.
5. If you are not our customer, or in any other instances where the law requires, we will only market to you by electronic communications with your consent.
6. You may opt-out of direct marketing campaigns at any time, at which point we will not send you any direct marketing related to a specific service or associated campaign. Should you decide to opt out of all, or any direct marketing received from us, you can either click on the following – https://www.nationaloptout.org/ or register on the do not contact list of the Direct Marketing Association of South Africa which can be found on www.dmasa.org.
7. In all cases you can request us to stop sending marketing communications to you at any time.
8. If we are providing you with services, you will also be subject to the specific terms and conditions relating to the product or services you are being provided with and these terms will include additional information as to how we or any of our customers or business partners may contact you.
9. If the reason you have given us personal information is to receive marketing communications from us, we will continue to provide this information to you unless you ask us not to do so.
9. SHARING PERSONAL INFORMATION
1. In general, we will only share your Personal Information if any one or more of the following apply:
i. If the law allows it.
ii. if, where necessary, you have consented to this.
iii. if it is necessary to conclude or perform under a contract, we have with you.
iv. if the law requires it; and / or
v. if it’s necessary to protect or pursue your, our or a third party’s legitimate interests.
2. Where required, we may share your Personal Information with the following persons. These persons have an obligation to keep your Personal Information secure and confidential:
ii. our employees as required by their employment conditions.
iii. participating partners in our customer loyalty reward programmes, where you purchase goods, products and service or spend loyalty rewards; and / or
iv. our joint venture and other partners with whom we have concluded business agreements
10. YOUR DUTIES AND RIGHTS ABOUT THE PERSONAL INFORMATION WE HAVE ABOUT YOU.
1. You have the right to request access to the Personal Information we have about you by contacting us.
2. This includes requesting:
i. confirmation that we hold your Personal Information.
ii. a copy or description of the record containing your Personal Information; and
3. We will attend to requests for access to Personal Information within a reasonable time.
4. You may be required to pay a reasonable fee to receive copies or descriptions of records, or information about third parties.
5. We will inform you of the fee before attending to your request.
6. Please note that the law may limit your right to access information.
7. You have the right to request us to correct or delete the Personal Information we have about you if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully or we are no longer authorised to keep it.
8. You must inform us of your request in writing.
9. It may take up to 15 business days for the change to reflect on our systems. We may request documents from you to verify the change in Personal Information.
10. A specific agreement that you have entered with us may determine how you must change your Personal Information provided at the time when you entered into the specific agreement. Please adhere to these requirements.
11. If the law requires us to keep the Personal Information, it will not be deleted upon your request.
12. The deletion of certain Personal Information may lead to the termination of your business relationship with us.
13. Where you have provided your consent for the processing of your Personal Information, you may withdraw your consent. If you withdraw your consent, we will explain the consequences to you.
14. We may proceed to process your Personal Information even if you have withdrawn your consent if the law permits or requires it.
15. It may take up to 30 business days for the change to reflect on our systems, during this time we may still process your Personal Information.
16. We will address your complaint as far as possible.
11. HOW WE SECURE PERSONAL INFORMATION
1. We are legally obliged to provide adequate protection for the Personal Information that we hold and to stop all unauthorized access and use of the Personal Information. We will on an ongoing basis, continue to review our security controls and related processes to ensure that your personal information is secure.
2. We take appropriate and reasonable technical and organisational steps to protect your Personal Information according to industry best practices.
3. Our security measures (including physical security, computer and network security, secure communications, security in contracting out activities and functions technological and procedural safeguards) will be appropriate and reasonable.
4. This includes the following:
i. keeping our systems secure (like monitoring access and usage).
ii. storing our records securely.
iii. controlling the access to our buildings, systems and/or records; and
iv. safely retaining or destroying or deleting records.
5. When we contract with third parties, we impose appropriate security, privacy, and confidentiality obligations on them to ensure that Personal Information that we remain responsible for, is kept secure.
6. You can also protect your Personal Information by always exercising caution.
1. A cookie is a small piece of data sent from our websites or applications to your computer or device hard drive or Internet browser where it is saved.
2. The cookie contains information to personalise your experience on our websites or applications and may improve your experience on the websites or applications.
3. The cookie will also identify your device, like the computer or smart phone.
4. By using our websites or applications you agree that cookies may be forwarded from the relevant website or application to your computer or device.
5. The cookie will enable us to know that you have visited the website or application before and will identify you.
6. We may also use the cookie to prevent fraud.
13. PERSONAL INFORMATION OF JURISTIC PERSONS AND PEOPLE RELATED TO JURISTIC PERSONS
1. If you are a juristic person (like a company or close corporation), we may collect and use Personal Information relating to the juristic person’s directors, officers, employees, beneficial owners, partners, shareholders, members, authorised signatories, representatives, agents, payers, payees, customers, guarantors, spouses of guarantors, sureties, spouses of sureties, other security providers and other persons related to the juristic person. These are related persons.
2. If you provide the Personal Information of a related person to us, you warrant that the related person is aware that you are sharing their Personal Information with us and that the related person has consented thereto.
14. HOW TO CONTACT US
If you have any questions about this policy and notice or need further information about our privacy practices or wish to give or withdraw consent, exercise preferences or access or correct your personal information, please contact us at email@example.com